Michael Reiter v. Richard D. Fairbank (Capital One Financial Corp.)

CourtCourt of Chancery of Delaware
DecidedOctober 18, 2016
DocketCA 11693-CB
StatusPublished

This text of Michael Reiter v. Richard D. Fairbank (Capital One Financial Corp.) (Michael Reiter v. Richard D. Fairbank (Capital One Financial Corp.)) is published on Counsel Stack Legal Research, covering Court of Chancery of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael Reiter v. Richard D. Fairbank (Capital One Financial Corp.), (Del. Ct. App. 2016).

Opinion

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE MICHAEL REITER, Derivatively on ) Behalf of CAPITAL ONE FINANCIAL ) CORPORATION, ) ) Plaintiff, ) v. ) ) C.A. No. 11693-CB RICHARD D. FAIRBANK, PATRICK ) W. GROSS, LEWIS HAY, III, MAYO ) A. SHATTUCK III, ANN FRITZ ) HACKETT, PIERRE E. LEROY, ) BRADFORD H. WARNER, PETER E. ) RASKIND, BENJAMIN P. JENKINS, ) III, and CATHERINE G. WEST, ) ) Defendants, ) and ) ) CAPITAL ONE FINANCIAL ) CORPORATION, a Delaware ) corporation, ) Nominal Defendant. ) )

MEMORANDUM OPINION Date Submitted: July 22, 2016 Date Decided: October 18, 2016 Blake A. Bennett, COOCH AND TAYLOR, P.A., Wilmington, Delaware; Brian J. Robbins, George C. Aguilar and Jay N. Razzouk, ROBBINS ARROYO LLP, San Diego, California, Attorneys for Plaintiff. S. Mark Hurd, Richard Li and Dean J. Shauger, MORRIS, NICHOLS, ARSHT & TUNNELL LLP, Wilmington, Delaware; Maeve L. O’Connor, DEBEVOISE & PLIMPTON LLP, New York, New York; Jonathan R. Tuttle and Anna A. Moody, DEBEVOISE & PLIMPTON LLP, Washington, District of Columbia, Attorneys for Defendants and Nominal Defendant. BOUCHARD, C. In this derivative action, a stockholder of Capital One Financial Corporation

asserts that its directors breached their fiduciary duty of loyalty and unjustly

enriched themselves by consciously disregarding their responsibility to oversee

Capital One’s compliance with the Bank Secrecy Act and other anti-money

laundering laws (“BSA/AML”). Plaintiff’s central allegation is that the directors

ignored red flags that Capital One’s BSA/AML compliance program failed to

satisfy statutory requirements relating to services Capital One provided to clients

engaged in check cashing, a business that poses an inherent risk for money

laundering.

Before filing this action, plaintiff prudently sought and obtained books and

records from Capital One under 8 Del. C. § 220. Those documents, which are

incorporated into the complaint, show that the board’s Audit and Risk Committee

and its successor committees received at least twenty-five reports over a three-and-

a-half-year period explaining the company’s BSA/AML compliance risk, which

escalated from “low” in early 2011 to “high” in early 2013, where it remained in

2014. Significantly, those same reports explained to the directors in meaningful

detail on a regular basis the initiatives management was taking to ameliorate

Capital One’s BSA/AML compliance risk, including management’s decision in

early 2014 to exit the check cashing business altogether, and none of those reports

reflected that the Company’s BSA/AML controls and procedures had been found

1 to violate statutory requirements or that anyone within Capital One had engaged in

fraudulent or illegal conduct.

Defendants have moved to dismiss the complaint under Court of Chancery

Rule 12(b)(6) for failure to state a claim for relief, and under Rule 23.1 for failure

to make a demand on the board before filing suit. As to the latter issue, plaintiff

contends that demand would have been futile because all ten members of Capital

One’s board when suit was filed, including nine outside directors whose

independence is unquestioned, face a substantial likelihood of personal liability for

the underlying claims.

The standard under Delaware law for imposing oversight liability on a

director is an exacting one that requires evidence of bad faith, meaning that “the

directors knew that they were not discharging their fiduciary obligations.” 1 For the

reasons explained below, I conclude after carefully reviewing the allegations of the

complaint and the documents incorporated therein, that plaintiff has failed to allege

facts from which it reasonably may be inferred that the defendants consciously

allowed Capital One to violate BSA/AML statutory requirements so as to

demonstrate that they acted in bad faith. Plaintiff thus has failed to plead with

particularity that a majority of Capital One’s directors face a substantial likelihood

1 Stone v. Ritter, 911 A.2d 362, 370 (Del. 2006).

2 of liability for the claims asserted in this case. Accordingly, demand would not

have been futile and the complaint will be dismissed with prejudice.

I. BACKGROUND

Unless noted otherwise, the facts recited in this opinion are based on the

allegations in the Verified Stockholder Derivative Complaint (the “Complaint”)

and the documents incorporated therein.2

A. The Parties

Capital One Financial Corporation (“Capital One” or the “Company”) is a

Delaware corporation headquartered in Virginia. It offers a broad spectrum of

financial products and services through its banking and non-banking subsidiaries.

The defendants were the ten members of Capital One’s board of directors

when plaintiff filed this action: Richard D. Fairbank, Patrick W. Gross, Lewis Hay,

III, Mayo A. Shattuck III, Ann Fritz Hackett, Pierre E. Leroy, Bradford H. Warner,

Peter E. Raskind, Benjamin P. Jenkins, III, and Catherine G. West. Fairbank, the

President and Chief Executive Officer of Capital One, was the only employee

director on the board.

In May 2013, the Audit and Risk Committee of Capital One’s board of

directors was split into two separate committees: the Risk Committee and the

2 I consider these documents in accordance with the incorporation-by-reference doctrine discussed below. See Part II.A.1.

3 Audit Committee. All defendants except Fairbank served on Capital One’s Audit

and Risk Committee or at least one of its two successor committees at some point

between June 2011 and January 2015, the time period relevant to this case.3

Plaintiff Michael Reiter alleges he was a stockholder of Capital One at the

time of the “wrongdoing complained of” and has been a stockholder continuously

since then.4

B. Capital One Begins Servicing Check Cashing Businesses

In December 2006, Capital One acquired North Fork Bancorporation, Inc.

and began providing banking services to check cashing and related money services

businesses in New York and New Jersey. The year before the acquisition, North

Fork entered into a memorandum of understanding with the Federal Deposit

Insurance Corporation and the New York State Banking Department concerning

weaknesses in North Fork’s program to comply with anti-money laundering laws

and the Bank Secrecy Act of 1970. As a result of the acquisition, Capital One

assumed North Fork’s obligations under the memorandum of understanding.

According to a 2014 report, Capital One considered exiting the business of

serving check cashers after the North Fork acquisition, but the New York State

Department of Financial Services encouraged the Company “to keep the business

3 Compl. ¶¶ 12-21. 4 Id. ¶ 10.

4 to serve the unbanked and underbanked.” 5 Capital One continued to serve check

cashing businesses in the decade following its acquisition of North Fork.

C. Regulatory Scrutiny of Check Cashing Businesses

Check cashing businesses are a significant focus of anti-money laundering

laws and regulations (“AML”), including the Bank Secrecy Act of 1970 (“BSA”)

(together, as defined above, the “BSA/AML”).

The Bank Secrecy Act of 1970, 6 as amended, requires financial institutions

in the United States to assist government agencies to detect and prevent money

laundering activities.

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